Privacy Policy (original) (raw)

Updated: January 1st, 2023.

Infolinks Media, LLC (AKA, Infolinks) is an advertising technology company that provides a variety of online advertising-related services. We respect all concerns about privacy issues and want you to be familiar with how we collect, use, and share information and how you can exercise the privacy rights available to you. This Privacy Policy (“Policy”) covers the information that we may process:

  1. About End Users through our Ad Services and Technology; and
  2. About individuals who visit, use, or interact with the Infolinks Properties.

If you are resident in the European Economic Area and want to find out more about the specifics of your data protection rights, please see “EEA Data Protection Rights” below.

To opt out of Infolinks Media ads click here.

SECTION 1 – WHO WE ARE

Infolinks provides advertising automation technology via our supply side platform (“Platform”) and related advertising tools (collectively the “Ad Services”). We provide our services and tools to our “Clients,” which include “Publisher Clients” who own and operate websites, mobile applications, and other online services (each a “Digital Property”) and “Media Buyers” who are advertisers and other ad partners looking to distribute ad content through our Platform to our “Publisher Clients”. Our Ad Services help Clients display relevant online advertising to end users (“End Users”) who interact with Digital Properties that use our Ad Services.

Infolinks also collects information from individuals when they visit, use, or interact with: (i) www.infolinks.com and other websites operated by us, including Infolinks’ client interfaces (the “Websites”); (ii) our software applications (the “Apps”); (iii) our social media pages (our “Social Media Pages”); and (iv) our sales and marketing activities (collectively, our “Infolinks Properties”).

SECTION 2 – PRIVACY FOR OUR AD SERVICES

This Section describes how we collect and use information we receive from End Users of Digital Properties that use our Ad Services.

2.1 WHAT INFORMATION DO WE COLLECT?

Information we automatically collect

When End Users visit a Digital Property that uses our technology, we (and our partners or vendors) use and deploy tracking technologies like cookies to automatically collect certain information about the End Users and their devices. Some of this information (including, for example, unique identifiers stored in a cookie or mobile advertising IDs) may identify a computer or device and may be “personal data” in some jurisdictions, including the EU. However, our Ad Services and Technology are designed to process information in such a manner that the information cannot be directly attributed to a specific, identifiable individual without the use of additional information (such as your name, address, or email address). In addition, we adhere to individual privacy laws in each jurisdiction.

We (and our partners or vendors) may collect this information the first time an End User interacts with a Publisher Client’s Digital Property that uses our Ad Services, and we may combine and associate this information with information we (or our partners) may collect about the End User’s interactions with other ads served through our Platform.

The information we may collect includes:

Information we receive from third parties

We may also combine, merge and/or enhance the information we collect about an End User with information collected from our Publisher Clients and third parties (like our data providers). For example, our Publisher Clients may also collect information that they choose to pass to us either directly through our Ad Services or through application programming interfaces (APIs), when our Ad Services connect to their systems.

2.2 HOW DO WE USE YOUR INFORMATION?

We use the information we collect for a variety of business purposes. For example, we use the information we collect for the following purposes:

2.3 COOKIES AND SIMILAR TRACKING TECHNOLOGIES

We use cookies and other similar tracking technologies (such as pixel tags and web or browser caches) to collect information automatically from End Users’ devices. They help us identify unique browsers or devices used by an End User and to perform functions like, for example, limiting the same ad from continuously reappearing, ensuring that ads are properly displayed on our Publisher Clients’ Digital Properties, and serving an ad to the End User. To opt out of our use of such technologies for interest-based advertising purposes.

SECTION 3 – PRIVACY FOR THE INFOLINKS PROPERTIES

This Section describes how we collect and use information when visitors interact with or use any of the Infolinks Properties (such as our Websites).

3.1 WHAT INFORMATION DO WE COLLECT?

Information that individuals provide voluntarily

Certain parts of the Infolinks Properties may ask visitors to provide personal information voluntarily: for example, we may collect personal information when a visitor registers for an Infolinks publisher or media buyer account, Becomes an Infolinks customer, expresses an interest in obtaining additional information about Infolinks or our products and services, subscribes to our marketing, or otherwise contacts us.

The personal information we collect may include contact information (such as name, address, telephone number, or email address) and contact preferences, and the nature of an individual’s request.

Information we or our third-party partners collect automatically

When using the Infolinks Properties, we or our third-party partners may automatically collect certain information from an individual’s device. In some countries, including countries in the EU, this information may be considered personal data under applicable data protection laws.

Specifically, the information we collect automatically may include IP address, operating system type and version, browser type and version, cookie ID, an individual’s activities on the Infolinks Properties, and other information about the individual’s system and connection and how the individual interacts with the Infolinks Properties and other websites.

3.2 HOW DO WE USE YOUR INFORMATION?

We may use information collected from the Infolinks Properties for the following purposes:

3.3 COOKIES AND SIMILAR TRACKING TECHNOLOGIES

We and our third-party partners may use cookies and similar tracking technologies on the Infolinks Properties to collect and use information about visitors.

3.4 USE OF INFOLINKS PROPERTIES BY MINORS

The Infolinks Properties are not intended for nor directed to individuals that are deemed to be children under applicable data protection or privacy laws, and we request that such individuals do not provide information through any of the Infolinks Properties.

SECTION 4 – GENERAL INFORMATION

4.1 HOW DO WE SHARE YOUR INFORMATION?

Information collected from our Ad Services and Infolinks Properties may be disclosed:

4.2 YOUR OPT-OUT CHOICES

Opting out of receiving electronic communications from us

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by clicking on the opt-out link within the email message that you receive from us. Please also note that if you do opt out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to our services from time to time.

4.3 YOUR DATA PROTECTION RIGHTS

You have the following data protection rights:

4.4 LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EEA END USERS AND VISITORS ONLY)

If you are a resident of the EEA, our legal basis for collecting and using personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we normally rely on our legitimate interests to collect personal information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your personal information, they include the interests described in the sections above.

In some cases, we may rely on your consent or have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we rely on consent to collect and/or process your personal information, we will obtain such consent in compliance with applicable laws.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contacting Us” heading below.

4.5 THIRD PARTIES

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including our vendors or any other third party operating any site or service to which the Ad Services or Infolinks Properties link. The inclusion of a link through the Ad Services or Online Property does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft or any other digital properties, app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with the Ad Services or Infolinks Properties.

4.6 HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We use reasonable organizational, technical, administrative, and physical safeguards to protect the personal information we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe and secure. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

4.7 RETENTION OF YOUR INFORMATION

We will retain personal information for the period necessary to fulfill the purposes outlined in this Policy and where we have ongoing legitimate business needs to do so (for example, to provide the Ad Services, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations) unless a longer retention period is required or permitted by law.

If you are an End User, we may retain information that we collect through the Ad Services based on our data retention limitations, or indefinitely. We use precise geolocation for the specific ad impression to which the geolocation relates, after which the geolocation information is aggregated with other geolocation data for use by us for analytical purposes. If we de-identify information we collect through the Ad Services, we may retain that information, in an aggregated format, indefinitely. In such cases, we commit to not re-identifying the information. If we are required to retain information to comply with a legal or audit obligation, we may store End User information for longer periods.

4.8 INTERNATIONAL DATA TRANSFERS

The Infolinks Properties and Ad Services are provided, supported, and hosted in the United States. If you are using these from outside the United States, be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States and other locations. These countries may have data protection laws that are different from the laws of your country of residence.

However, we have taken specific and appropriate safeguards to require that your personal information will remain protected in accordance with the EEA and European Union data protection law.

4.9 UPDATES TO THIS POLICY

We will review and update this Policy periodically and will note the date of its most recent revision at the top of this Policy. If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you about such changes if required by applicable data protection laws. We encourage you to review this Policy frequently to be informed of how Infolinks is protecting your information.

4.10 CONTACTING US

If you have any questions about this Policy or Infolinks’ privacy practices, please contact us by email at privacy@infolinks.com, or by mail using the details provided below.

Please note that email communications are not always secure, so please do not include sensitive information in your emails to us.

Contact Information:

Infolinks Media, LLC c/o Privacy
3 N Maple Avenue, Suite #1
Ridgewood, New Jersey 07450, USA

To comply with our obligations under EU data protection legislation, we have appointed a Data Protection Officer (DPO). Our DPO is contactable at privacy@infolinks.com using the subject “Data Protection Officer:”, or by mail using the details provided above.

Who is the controller of my data? For the purposes of EU data protection legislation, Infolinks Media, LLC is the controller of your personal information.

SECTION 5 – EEA Data Rights Explained

Infolinks has adjusted our technology and policies specific to users in the EEA to fully comply with GDPR and adopt the TCF (transparency consent framework) for all data activity. We will be defaulting our systems to a No-Consent interaction when it’s not possible to determine Consent. No-Consent default means we will perform the following actions:

  1. Location masking by removing the last octet from the IP address of all EEA end users to de-identify such information and mask latitude/longitude
  2. No cookie syncing or cookie targeting by default unless compliant
  3. Pass a digital ‘No-Consent’ notification to all advertising partners by default
  4. Ensure any vendor activated on our publishers have appropriate compliance
  5. working with publishers to receive valid ‘User Consent’

In addition, Residents of some countries, including those in the European Economic Area, have data subject rights available to them under applicable data protection laws. These rights may include the right to request access to, or to request erasure or portability of, your personal information. You may also have a right to object to, or request that we restrict, processing of your personal information. Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable data protection laws.

If you make a request to access personal information we hold about you (also known as an “access request”), we will provide the Digital Identifiers of your browser(s) and/or device(s) that we may store. Additionally, we may also provide you with certain other information that we may have stored and associated with your Digital Identifiers.

Please note, however, that for detailed information we have a very short retention period for most files with Digital Identifiers. As a result, we may not be able to provide you with any records at all in response to an access request. In such cases, however, we will inform you that we have not been able to locate any records associated with your Digital Identifiers.

Important Note: We have a responsibility to verify your identity before we respond to an access request. This is to make sure that we provide a copy of your personal information only to the person who is entitled to it — you. Because of this, it is our policy not to accept requests submitted by third parties (including automated robots), and to require certain documentation from you to verify that you are authorized to make the access request. If you wish to make an access request, we kindly ask that you contact us directly and follow the instructions below.

Representative for data subjects in the EU and UK

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/13666019965

SECTION 5A – Additional Information for California Residents Explained

If you are a resident of California, please review these additional privacy disclosures.

Your Rights

California law requires us to disclose the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information, which we have explained above. We are also required to communicate information about rights you have under California law—for information about these rights, please ​review the complete document​ above. You also have the right to request what information we collect and how we use and disclose it. You may exercise these rights by ​submiting our disclosure form. Please note that because most of the information we store can only identify a particular browser or device, and cannot identify you individually, you need to provide us with some additional information to enable us to identify the User Information we hold about you, if any, and ensure that we accurately fulfill your request. If you have any questions about your rights or our disclosures, you may reach us at ​+1.INFO.LNK

In addition, we are required to provide you certain information about the business and commercial purposes for which we collect and share your personal information. We use and disclose the information we collect for the business purposes described ​throughout the document of this policy, including: to allow our clients to select and display advertisements, to understand how users interact with our services, for auditing purposes, to detect security incidents, to prevent fraud, debug, and repair errors, and for other purposes described above.

HOW TO MAKE A DATA SUBJECT RIGHTS REQUEST

If you wish to make a data subject rights request, please follow the steps described below:

Step 1: Locate Your Digital Identifiers

In order for us to locate relevant records, we will need you to provide us with your Digital Identifiers. You can find your Digital Identifiers as follows:

As described throughout the Privacy Policy our technology operates by using text files called “cookies” that are placed on your device. See the applicable policy for more information about the cookies we use, and how to manage cookies and other similar technologies. Some of the cookies we use include a Digital Identifier. To locate these Digital Identifiers, you can search through your cookies for the cookies named in our cookie policies (which are set from the Infolinks domain). The text in each of these cookies is a separate Digital Identifier.

Please keep in mind that different cookies are placed on each browser and device that you use to access the Internet. As a result, if you use multiple browsers (for example, Google Chrome and Mozilla Firefox) and devices (for example, a laptop computer and a mobile phone), you will need to locate the applicable cookies for each browser and device.

Additionally, certain mobile devices (for example, mobile phones or tablets using the iOS or Android operating systems) generate a persistent “Advertising Identifier” per device, which, among other things, can be used by third parties for purposes of providing you with targeted advertising. On iOS devices, your Advertising Identifier may be referred to as an “IDFA,” “IFA,” or an “ID for Advertising.” On Android devices, your Advertising Identifier may be referred to as an “Advertising ID.” Please follow instructions from your mobile device manufacturer on how to locate your specific Advertising Identifiers.

Step 2: Verify Your Digital Identifiers

In order to make sure that we are responding only to the person who is authorized to make the access request, we also will need some supporting proof to demonstrate that you are indeed connected to the Digital Identifiers you located in Step 1. For Digital Identifiers stored in cookies, please take a screenshot of each cookie, taking care to make sure that the screenshot shows both the name of the cookie and the full Digital Identifier. For Digital Identifiers located on a mobile device, please take a screenshot of a screen that displays the Digital Identifier. Additionally, please fill out, sign and include in your request the ‘Infolinks Data Authorization Form’ in Section -A- below that we have prepared, which attests that the Digital Identifiers you have located are indeed associated with you. By signing the form, you declare, under penalty of perjury, that all statements made on the form are true, and you must also have a witness sign and date the form. By signing the form, the witness declares, under penalty of perjury, that your signature on the form is genuine. In addition, you and the witness must each provide a copy of one identifying document, such as a passport or driver’s license. The names on the document copies must match the printed names on the Authorization Verification Form. We require these steps to help us verify that you, as the data subject of the personal information you have requested, are authorized to request and receive such personal information.

Step 3: Contact Us

Once you have located your Digital Identifiers and can provide us with verification of those Digital Identifiers as instructed above, please contact us with details of the data subject rights you wish to exercise. The easiest way to do so is to email us at privacy@infolinks.com. Your completed Authorization Verification Form located below in SECTION -A- and required documentation must be attached to the email as PDF files. Please make sure to include the following information in your email:

You can also make a data subject rights request by postal mail, by sending a written request with all of the above-listed information to our contact address:

Infolinks Media, LLC c/o Privacy
45 Broad Street, Second Floor
Ridgewood, New Jersey 07450, USA

SECTION 6 – WebSite and Platform Cookie Policy

This Cookie Policy describes the different types of cookies that may be applied on the equipment of consumers who visit Infolinks.com and any other websites (the “Sites”) owned and operated by Infolinks, Inc. and its affiliates (collectively, “Infolinks”).

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please, therefore, re-visit this Cookie Policy regularly to stay informed about our use of cookies and similar technologies. The date at the top of this Cookie Policy indicates when it was last updated.

If you have any further queries, please contact us by email at privacy@infolinks.com.

WHAT IS A COOKIE?

Cookies are a standard feature of websites that allow us to collect certain information from your browser or device when you visit our Sites. In relation to the use of cookies by our partners and clients, note that we do not have access or control over these cookies.

WHAT COOKIES DO WE USE?

We use a variety of cookies on the Infolinks Sites and Platform for several reasons. We also may use weblogs, pixel tags, or web beacons, which are pieces of code that may be used to read and place cookies on a web browser, to collect information about how you interact with websites or advertisements.

The sections below describe the types of cookies most frequently used by Infolinks on the Sites and explain their use.

Essential Cookies

We use cookies that are essential to making the Sites work. These types of cookies enable you to move around the Sites and use their features. For example, we may use cookies to record a user login, manage user sessions, authenticate users of our management apps, or adjust settings and functionality on the Sites. Without these cookies, we may not be able to provide the services that are necessary for you to be able to use the Sites, such as signing into your account.

Preference Cookies

We also use cookies that collect information about your choices and preferences. These cookies allow us to remember language or other local settings and customize the Sites accordingly. For example, we may store settings and preferences of our logged in users.

Social Media Cookies

Some of the pages on the Sites contain tools or applications that are linked to third-party social media service providers such as Facebook, Twitter, and LinkedIn. The social media service provider may set its own cookies on your computer or device through these tools or applications. You should check the social media service provider’s website for further details about how they use cookies.

Analytics Cookies

These cookies collect information about how people are using the Sites, for example, which pages are visited the most often, how visitors move from one webpage to another, and whether visitors experience any difficulty using the Sites. Overall, these cookies provide us with analytical information about how the Sites are performing and how we can improve it, and in some instances, whether our advertising is effective or not. Such cookies are: Google Analytics, SalesForce, and others.

Advertising Cookies

We may partner with certain third parties to deliver advertising that we believe may interest you based on your activity on our Sites and other websites over time. These third parties may set and access cookies on your computer or other device and may also use weblogs, pixel tags, or web beacons. These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of the advertising campaign. Such cookies are: Quantcast, and others.

HOW DO I MANAGE COOKIES?

You have the right to decide whether to accept or reject cookies. In addition to the options provided above, you may refuse or accept cookies from the Sites at any time by activating settings on your browser. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. You may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please be aware that if cookies are disabled, some website features may not operate as intended.

SECTION -A-

Please Submit the Data Subject Access Request by mail to the contact address in Section 4.1, or as a PDF attachment as seen in Section 4.10:

DATA SUBJECT ACCESS REQUEST – AUTHORIZATION VERIFICATION FORM

I, the undersigned Data Subject, hereby swear, certify and attest that:

  1. I am a citizen and/or resident of _________________________________________, which is located within the ________________ Area;
  2. Please complete for the access you are requesting:

¨[ ] I own and operate a device on which is stored at least one cookie listed in Infolinks’s Platform Cookie Policy or Website Cookie Policy, which is set by the Infolinks domain, and contains the following string(s) of text: _______________________________________________________________________; _______________________________________________________________________;

  1. [ ] I have the authority, under relevant laws, rules and regulations, to submit a subject access request for personal data associated with the above-listed identifiers; and
  2. [ ] I am not requesting this information for any fraudulent, criminal, malicious or other unlawful or improper purpose.
  3. I have followed the directions and provided all information required by the Infolinks Data Subject Rights Notice.

DATA SUBJECT: By signing this form below, I declare under penalty of perjury that the foregoing is true and correct. ____________________________ Name of Data Subject (print)

______________________

Date of Signature

____________________________

Signature of Data Subject

WITNESS: By signing this form below, I declare under penalty of perjury that, based on my personal knowledge, the signature above is the genuine signature of the Data Subject named above.

Date of Signature

______________

Name of Witness (print)

____________________________

Signature of Witness

____________________________